WE HAVE AN INJURY! THE HORSE IS OUT OF THE BARN! LAGGING OR LEADING SAFETY INDICATORS?

Per 29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses most employers in the United States must document and report their major work-related injuries.  An employer is required to document and track work-related injuries or illnesses that require medical attention above what is considered “First Aid.”  In most cases seeing a medical doctor for an injury is an injury above First Aid. This type of injury is a called an OSHA Recordable because it must be documented on the OSHA 300 Injury Log for this organization (for exceptions see Appendix A to Subpart B 1904).  

In the past, if requested, employers must report their injuries from the OSHA 300 Log to the Bureau of Labor Statistics (BLS) annually via another form, a Survey of Occupational Injuries and Illnesses (29 CFR 1904.42 Requests from the Bureau of Labor Statistics).  This is now done online at the BLS website. OSHA is presently embroiled in a controversy between the Obama and Trump administration as to forwarding large organizations’ OSHA 300 Logs directly to them on an annual basis. OSHA changed their requirements, via directive, for reporting severe accidents to one that now requires cases that require over-night hospitalization, amputation, or death to be reported to directly to OSHA within 24 hours, 8 hours for fatalities of an incident.         

In college, in Safety 101, they teach you about the Safety Pyramid.  Which basically illustrates the relationship of the degrees of work-related injuries. The exact layout and definition of the Safety Pyramid varies by authority. For the sake of this article, we will divide the Safety Pyramid into five categories, from the top:

1. Fatality is the worst, the unthinkable. One will devastate an organization. Anyone that has been through one does not even want to think about. As of this writing the latest OSHA information is for 2016. In that year there were 5,190 deaths due to work-related injury in the United States.  
2. Recordable Injury is described above. In the latest 2016 statistics there were 2.9 million non-fatal OSHA Recordable and Injuries in the United States. About one third of these Recordables resulted in a special class called Days Away from Work or what many people simply call Lost Time Injuries. By definition a Lost Time, is anytime an employee misses an entire work shift due to an injury. If an employee experiences an OSHA Recordable and only misses six hours of his 8 hour shift it is NOT considered a Lost Time Injury until such time he misses one complete shift.  
3. First Aid is an actual injury but is relatively minor in scope. A small cut that requires a topical cream and a small band-aid might be an example. This class is basically any injury where someone has not seen a medical professional, again depending on state, this is usually considered a medical doctor or similar. However, it is not so much the type of health care provider seen by the employee; it is much more about the level and care prescribed. Although this type of injury is not required to be tracked, in general the more incidents you can document the better.   
4. Near Miss Incidents are what I call, “Almost Happened Accidents!” This is where an incident has occurred but no injury actually takes place. An example might be where an employee trips on an object on the floor but manages to catch themselves before they completely fall and injure themselves. Near Misses most often go unreported, by employees, for a variety of reasons.   
5. Unsafe Acts by a huge percentage are the root cause of all injuries. The usual definition is where: 

Someone does something they should not do. 

Someone does not do something they should do.                                              

The phenomenon of Unsafe Acts is the basis for an entire school of Safety Management called Behavioral Based Safety (BBS). An Unsafe Act differs from a Near Miss because no actual incident occurs. In the Near Miss example above may be the employee stepped over the object and did not actually trip. It is very rare occurrence for Unsafe Acts to be reported by employees.

These first three types, First Aid, Recordables, and Fatalities are called Lagging Metrics. A Lagging Metric basically means the incident has happened. Hopefully, we can diagnose the root cause for the injury and prevent a similar injury to another employee, but we have an injured employee on our hands.  As my grandfather use to say, “The horse is out of the barn!” 

For most of my long career I worked hard at recording and analyzing OSHA Recordable Injury data. I like many other HR and EHS professionals would spend a great deal of time making many charts and trying draw inferences from them. Many of the charts would be used in corporate presentations with further inferences made. All this analysis allowed us to husband our resources accordingly. This fact with our ever increasingly effective Safety Management Programs we were able to drive the number, frequency, and severity of instances down. In my business, we drove the OSHA Recordable Rate (per 100 employees) from the mid-teens to under 1.0. That means just in pure numbers we went from about 40 to 70 Recordables per year to 10 or less. If I remember my college statistics correctly there is a term called statistical significance that comes to mind. As I further recall statistical significance is reduced as the sample sized is reduced. To someone that barely got through their college stats requirements, that means when you do not have the numbers, the numbers just not mean as much any longer; as far as looking for trends and drawing conclusions. Basically, as we drained the swamp we had to look elsewhere to measure ourselves.

So, what does one do? You are driving the numbers down, but now you do not have reliable numbers to point you in the correct direction any longer. Again, looking back at the Safety Pyramid the natural thing to do is look towards where there are more numbers, that means looking down towards the base of the Safety Pyramid to First Aid Cases. By looking at First Aid Cases we discovered more numbers we also found a high correlation to our Recordable Data. For example, we found if our Cuts and Abrasion Category First Aid number went up it was highly likely that our Laceration Category Recordable number would rise as well. Overall, we also were able to start seeing a correlation to the ratio of First Aid Cases to Recordables. For example, if we were getting one Recordable to twenty (1/20) First Aid cases, when we got to 15 First Aid cases we knew we were living on the edge and a Recordable could be imminent. It was not a 100% but the correlation was there. Which is another premise of the Safety Pyramid, “If you can cut down on the lower severity cases you will cut down on the higher severity cases!” Which led me to think for many years I had been looking the wrong way. For the longest time, we were only looking at Recordables and then looking down. We discovered, and rightly so, that we should be starting at the bottom and looking up the Safety Pyramid.     

 Near Misses and Unsafe Acts on the bottom of the Safety Pyramid are considered “Leading Indicators.” Most EHS professionals today now believe the true course to a World Class Safety Program is to concentrate on the Leading Indicators. If we can get a good handle on the behaviors that lead to injury we might be able to stop an actual injury before it happens, whether it be a First Aid Case, Recordable, or Fatality. Going back up to the Near Miss and Unsafe Act example in the definitions above, if we can stop the person from allowing the object to be on the floor in the first place, we can prevent any injury of any kind. Simply put, the difference between Leading Indicators and Lagging Indicators is the difference between something we hear all time these days, the difference between being Proactive or Reactive. 

It is so easy to just say we should just cast-off Lagging Indicators and concentrate on Leading Indicators in our Safety Measurements and Management Programming. However, there are three major barriers that can be very tough to overcome.

1. Getting employees to report Near Misses and Unsafe Acts is a daunting task at best. Who is going to admit they did something that was unsafe? Who wants to risk embarrassment or maybe even sanction by management? Not a lot of people want to admit they are human! It is one huge challenge to get employees to admit when they are doing unsafe things, and even harder to get them to bring them forward. So much so that if you could come up with a reliable system to do so, you would be infinitely wealthy. Getting this data is often very difficult. 
2. The tendency to rely on Lagging Metrics is so entrenched in many or our cultures. For decades my annual performance review and that of my organization from our corporate bosses depended the number of injuries we had. In my organization it is always has been one of the most important metrics, right up there with earnings. Trying to break that thinking can also be very hard for an organization.  
3. Breaking with Lagging Metrics, requires to a certain degree, a leap of faith. In your gut you may absolutely know moving to Leading Indicators is essential for the future, however, trying to prove it logically, especially to numbers managers or those managers governed by pure logic sometimes are difficult to convince. 

In my experience, those companies that are embracing Lean Manufacturing or Lean Process Improvement seem to find it easier to make the change to Leading Indicators easier than those that are not.  For companies that are implementing Lean the leaps of faith seem to become easier and easier. New thinking just becomes status quo. However, I think the part of Lean that seems to be most compatible is the overall culture change based on trust which is conducive to Teambuilding. Lean philosophy is not absolutely required to make the switch to concentrating on Leading Indicators, but it sure helps.

 As professionals that want to keep our employees safe there probably always has to be some reliance on looking at actual injuries. After an injury we have an injured teammate on our hands. Our tendency in the past, was to concentrate on that one injury. Maybe the injury was a lacerated finger requiring several sutures. Typically, we would concentrate on an injury investigation and we might discover that the root cause was that the employee was cutting a box open and the box opener slipped and the employees finger got in the way. As a fix we require employees wear cut-resistant gloves for employees cutting boxes. In our old thinking we would have a tendency to move on to something else. However, what are we missing?

If we are looking proactively and at Leading Indicators we might discover via Near Miss Reports that the incidence of employees almost cutting themselves is rising.  If we are on the ball, we would then look at the overall problem of lacerations.  There are probably more reasons to lacerations then just cutting boxes. By addressing the overall issue, we might be able to avoid not just this one actual laceration but maybe most or all laceration injuries. Looking at Leading Indicators can pay huge dividends!

I have always been a big proponent of Safety Incentive Systems, yes Safety Games. You might say, “Safety is no game!” I would agree with that statement, but more importantly I do believe in getting as many people involved in safety programs as possible to build ownership and engagement. Safety Incentive Systems do just that if they are designed properly. Over ten years ago we had programs that used OSHA Recordables or Lost Times as the central metric in these games. However, OSHA now takes a very did view on such programs as they tend to suppress real accident reporting. So, we are forced to use other metrics. This gives you a reason to gather Leading Indicator data. You can also include such things as Safety Training or Safety Team Participation which are also things you might want to promote.

In my experience, Safety Incentive Systems may do a nice job at promoting submission of Near Misses. However, to be successful at employees reporting Unsafe Acts, especially of other employees, will also demand a huge culture shift to learning and trust for the organization. If you have an organization that is gathering a large number of Unsafe Acts you truly are special and a World Class Safety Organization!            

In my opinion, if you want to keep chasing the horse once he is out of the barn stay with an emphasis on Lagging Metrics. You will in the end run, find yourself, chasing your own tail. However, if you move towards, concentrating on Leading Indicators, you can keep the horse in the barn! Are we going to chase the horse’s tail around the farm or are we going to lead him to the water in the barn? I prefer to be the horse’s partner not adversary.

If you like my articles you can find more on my website or LinkedIn Profile Page. If I can be of service either by just bouncing something off me or asking my assistance please do under no obligation! Your feedback is very much appreciated on anything especially this article. Thank you! Fitz

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